EFTA00605112.txt

"GHISLAINE MAXWELL. Defendant. 15-cv-07433-RWS"

"Ms. Sharon Churcher, Plaintiff's friend, advocate and former journalist with the Daily Mail"

"she directed her agent, Ross Gow, to attack"

"the failure to timely secure the depositions... is through no fault of Ms. Maxwell"

"Plaintiff has had over eight months to subpoena witnesses"

"Mr. Gow resides in London"

"Plaintiff's former fiancé, a witness who is hostile"

"Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way around."

"this defamation matter (where none of those individuals are parties) based on an 'adverse inference' that can be drawn against Ms. Maxwell"

"Attorneys for Ghislaine Maxwell"

"Attorneys for Ghislaine Maxwell"

"DEFENDANT'S COMBINED MEMORANDUM OF LAW IN OPPOSITION TO EXTENDING DEADLINE TO COMPLETE DEPOSITIONS"

"Plaintiff's friend, confidante and former-Daily Mail journalist, Sharon Churcher"

"Mr. Epstein's attorney agreed to accept service on April 11, 2016... Mr. Weinberg's email offering to accept service"

"Laura A. Menninger... HADDON. MORGAN, AND FOREMAN, P.C... DEFENDANT'S COMBINED MEMORANDUM OF LAW"

"Jeffrey S. Pagliuca... HADDON. MORGAN, AND FOREMAN, P.C... DEFENDANT'S COMBINED MEMORANDUM OF LAW"

"Laura A. Menninger... HADDON. MORGAN, AND FOREMAN, P.C."

"Jeffrey S. Pagliuca... HADDON. MORGAN, AND FOREMAN, P.C."

"Plaintiff and Epstein fully resolved any claims against one another by way of a confidential settlement in 2009"

"Defendant's former boyfriend, employer, and co-conspirator"

"Defendant's former boyfriend, employer, and co-conspirator"

"Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C."

"Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP"

"Plaintiff's counsel finally responded with 'as is becoming clear'"

"Plaintiff ignored that request"

"S. McCawley ... [email protected] ... BOIES, SCHILLER & FLEXNER, LLP"

"Meridith Schultz ... [email protected] ... BOIES, SCHILLER & FLEXNER, LLP"

"Bradley J. Edwards ... FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN"

"provided addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan Dershowitz"

"his objection that he is a resident of the U.S. Virgin Islands"

"Plaintiff's own counsel have strenuously litigated in other cases that Mr. Epstein is a resident of Florida"